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BITMINE IMMERSION
TECHNOLOGIES, INC.

2030 Powers
Ferry Road SE, Suite 212

Atlanta, Georgia
30339

April 15, 2024

Mr. David Irving

Michelle Miller

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549-3561

 Re: Bitmine Immersion Technologies, Inc.

    Form 10-K Filed December 14, 2023

    Form 10-Q Filed January 12, 2024

    File No. 000-56220

Dear Mr. Irving and Ms. Miller:

Set forth below are the responses of
Bitmine Immersion Technologies, Inc. (the “Company”, “we”, “us” or “our”)
to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter dated March 1, 2024, with respect to the Company’s Form 10-K for the
year ended August 31, 2023 and its Form 10-Q for the quarter ended November 30, 2023 (the “SEC Reports”). The Company
is also simultaneously filings its Form 10-Q for the three months ended February 29, 2024 (the “Current Form 10-Q”,
in which other comments have been addressed.

Form 10-K For the Fiscal Year Ended August
31, 2023

Company Overview, page 1

 1. Refer to prior comment 4, to comment 8 in our letter dated August 28, 2023, and to your responses to these comments and disclosures
in this filing. We do not see disclosure regarding the total hashing power of the pool in which your miners participate and the percentage
thereof contributed by your miners, how that pool holds your proportion of mining rewards and the duration thereof, whether the pool operator
has insurance for theft or loss and risk factor disclosure related to transferring crypto assets. Also, in your January 12, 2024 response
you advised that you disclosed the material terms of your mining pool agreement in your Management’s Discussion and Analysis of
Financial Condition and Results of Operation and the notes to your financial statements, yet your most recent form 10-K doesn't appear
to disclose material terms of the mining agreement. Furthermore, your October 6, 2023 response letter advises that you will revise future
filings to disclose the percentage of hashing power of your self-mining operations allocated to each pool for each accounting period in
the notes to the financial statements, and we see no such disclosure. Please direct us to the above disclosures or please provide draft
disclosures and confirm these disclosures will be included in future filings.

Response: As we believe was explained in response
to the comments, the Company did not disclose the total hashing power of the pool and the percentage contribution by its miners because
it is not relevant to the amount of rewards paid to the Company, and therefore is not shared by the pool operator. The Company disclosed
that the mining pool operator calculates revenues in 24 hour increments, and pays each day’s revenue within 24 hours after the end
of each day. See “Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operation –
Critical Accounting Policies – Revenues from digital currency mining – General - Step 3.” The Company also disclosed
that it used only one mining pool during the year ended August 31, 2023. See “Item 7. Management’s Discussion and Analysis
of Financial Condition and Results of Operation – Critical Accounting Policies – Revenues from digital currency mining –
General.” As explained in the initial response to this comment, we do not know if the pool operator has insurance against loss
but we do not consider the risk to be material because the pool operator normally holds only one day of mining rewards and the Company
has the ability to terminate its contributions to the pool at any time. Also, there is a risk factor disclosing that none of the bitcoin
owned by the Company is insured, which would necessarily include bitcoin held on our behalf by the pool operator.

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 2. You state that you "plan to operate [y]our data centers using immersion cooling technology." In future filings please
revise this statement to also clarify the extent to which your operations currently use immersion cooling technology.

Response: Beginning with the Current Form 10-Q,
the Company will include a count of the miners that are immersion cooled miners versus air-cooled miners in future filings.

Part I

Item 1. Business, page 1

 3. Please clarify in the business section of future filings your intentions to mine digital assets other than bitcoin. Refer to comment
7 in our August 28, 2023 letter and to your response on October 6, 2023 that in future filings, including this Form 10-K, you would revise
to "better reflect what has been mined to date and the future intent with regard to other types of digital assets." Please advise
where in the document you clarify your intent regarding mining digital assets other than bitcoin or provide draft language you intend
to include in future filings. We note your statements that that mining activities to date have been limited to Bitcoin and other disclosures
in your risk factors on pages 22, 28 and 44 referencing "other cryptocurrencies we mine" or "any other digital assets we
mine."

Response: We do not believe the references to “other
digital assets [cryptocurrencies] we mine” in a few risk factors means that the Company mines any assets other than bitcoin presently.
The Company has made clear in three other places that it has only mined bitcoin to date, but reserves its right to mine other digital
currencies. The language cited from the risk factors merely covers the possibility that the Company owns or mines other digital assets,
without representing that it actually does. Nevertheless, Item 1A. Risk Factor in the Current Form 10-Q includes amended versions of the
three risk factors to clarify that the reference to other digital assets or cryptocurrencies does not mean that the Company actually owns
or mines them.

 4. We note your response to prior comment 2. In future filings please include a more comprehensive breakeven analysis for your bitcoin
mining operations that compares the cost to earn/mine one bitcoin with the market value of one bitcoin. Your analysis should identify
and explain all relevant inputs used in your calculation, regardless of whether various inputs are discussed elsewhere in separate parts
of your filing. As part of your analysis please include the cost of acquiring mining equipment and any related financing costs.

Response: Most miners that include a
breakeven analysis do not include the depreciation of mining equipment, but at least one does, and therefore the Company will include
depreciation associated with its miners in the breakeven analysis, beginning with the Current Form 10-Q. As far as we can determine, no
other miners include financing costs of miners in their breakeven analysis. The Company does not believe there is any practical way to
separate financing costs of miners given the nature, terms and use of proceeds from the debt and equity financings in which the Company
has engaged to date, and we believe that others have reached the same conclusion.

Trinidad Operations, page 3

 5. In future filings please revise your statement in the second paragraph that "our rate for electricity will be TSTT’s
existing rate of 3.5 cents per kwh" to state, if true and as stated in the paragraph above, that "[y]our hosting containers
will be billed for electricity usage at the local utility’s standard rates, which is the greater of 3.5 cents per kwh or 75% of
the declared reserve capacity, which is equal to the customer’s highest expected monthly kilovolt-ampere demand at $7.40."
Please also revise the similar statement on page 12.

Response: In future filings, we will include the
entire formula which governs the electricity rates that we are charged in our Trinidad operations.

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 6. You state that "[w]hile [y]our TSTT site was delayed pending electrification, [you] entered into a hosting agreement with
a third party in Trinidad to host up to 192 miners in one immersion container until August 31, 2024." In future filings please disclose
the electrical rates you have been paying at this location.

Response: In future filings, we will disclose the
electricity rate for the 192 miners hosted by a third party in Trinidad.

Revenue Sources, page 5

 7. We note your disclosure on page 46 that you "generally liquidate [y]our bitcoin within 2-3 weeks of receipt in order to pay
operational expenses. Therefore, [you] do not expect to incur material losses on bitcoin that [you] hold due to the short holding period.
However, the volatility of bitcoin prices makes it more likely that [you] experience losses from holding bitcoin, which could have a material,
adverse impact on [y]our liquidity and [y]our business." In future filings please revise this risk factor to address the fact that,
as stated on page 5, you do not have a set policy in regard to how long you hold digital assets that you receive as payment. Address how
the lack of such policy could exacerbate the volatility risk from holding bitcoin.

Response: The revised risk factor is included in
Part II, Item 1A, Risk Factors of the Current Form 10-Q.

 8. We reissue comment 10 in our letter dated August 28, 2023. In future filings please reconcile your disclosures regarding whether
you hold or plan to hold crypto assets for investment. For example, on page 6 you state that you "do not plan to hold any digital
assets that [you] receive as a long-term investment," however on page 2 you state that you "may hold [y]our digital assets as
investments in anticipation of continued adoption of digital assets as a 'store of value' and a more efficient medium of exchange than
traditional fiat currencies." Likewise on page 56 you state that you "reserve the right to hold [y]our digital assets as a long-term
investment." We note that in your October 6, 2023 response letter you advised that the "proper statement of the Company’s
intent is the first statement, and the second statement will be removed or revised to be consistent with the first."

Response: The proper statement of intent is that
the Company does not currently hold digital assets for long-term investment, but reserves the right to do so in the future. The Company
believes that saying it “may” hold bitcoin as a long-term investment is not inconsistent with that general statement of its
intent. In future filings, we will endeavor to make that intent clear in all places where the issue is discussed, and indicate when the
Company holding period has changed, if that ever occurs.

Key Factors Affecting Our Performance

Halving, page 10

 9. Refer to prior comment 5, your response and your disclosures. We note that you have not included the requested cross-reference
in either your most recent Form 10-K or 10-Q filings. Please confirm that you will revise the halving disclosure in your Business section
of future filings to provide a cross-reference to your risk factor on the risks of halving.

Response: We will endeavor to include a cross-reference
to the cited risk factor in future filings.

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Item 7. Management's Discussion and Analysis
of Financial Condition and Results of Operations Critical Accounting Policies, page 62

 10. We note your response to comment 7 and that you recognized an impairment of fixed assets of $122,950 for the year ending August
31, 2023. Please enhance future filings to reflect your response and include a subheading for property and equipment. We note that within
your critical accounting estimates discussion you separately discuss revenue recognition, cash and cash equivalents, cryptocurrency, stock-based
compensation, related party transactions, net loss per share and income taxes but not property and equipment. Please also revise the header
of your discussion from Critical Accounting Policies to Critical Accounting Estimates. Refer to Release No. 33-8350 Interpretation: Commission
Guidance Regarding Management's Discussion and Analysis of Financial Condition and Results of Operations and Item 303(b)(3) of Regulation
S-K.

Response: In future filings
we will revise the header from “Critical Accounting Policies” to “Critical Accounting Estimates,” and in the
annual reports we will include a subheading for property and equipment. In the quarterly reports, we simply cross-reference the
applicable disclosure in the notes to the financial statements and expect to continue that process going forward. Regarding
disclosure of the $122,950 impairment loss, we intend to include enhanced narrative disclosure of material transactions relating to
property and equipment in the financial statement note concerning same, beginning with the Current Form 10-Q.

Item 12. Security Ownership of Certain
Beneficial Owners and Management and Related Stockholder Matters, page 78

 11. We note your response to prior comment 8. We note that the percent of common stock column in the table on page 78 does not compute
based on the shares beneficially owned and the 49,665,649 shares of common stock issued and outstanding at December 1, 2023.

 • For example, you disclose 23,595,583 shares beneficially owned by Jonathan Bates, which represents
47.5% of common stock based on 49,665,649 shares of common stock issued and outstanding at December 1, 2023, not 41.0% as disclosed in
the percentage of common stock column; and

 • For example, you disclose 16,786,887 shares beneficially owned by Innovative Digital Investors Emerging
Technology, LP, which represents 33.8% of common stock based on 49,665,649 shares of common stock issued and outstanding at December 1,
2023, not 30.5% as disclosed in the percentage of common stock column.

We note these computational discrepancies
for all beneficial share owners. Please revise future filings to address these concerns. Show us what your proposed disclosure will look
like in your response, or advise otherwise.

Response: We believe that the percentages are correct.
The percentages were calculated in accordance with Item 403 of Regulation S-K, which generally provides that beneficial ownership is calculated
in accordance with Rule 13d-3. Rule 13d-3 requires that beneficial ownership include any shares owned plus any shares that the holder
has the right to acquire within 60 days. Rule 13d-3 also addresses how to calculate the numerator in situations where a person’s
ownership includes shares that are not yet issued, as follows: “Any securities not outstanding which are subject to such options,
warrants, rights or conversion privileges shall be deemed to be outstanding for the purpose of computing the percentage of outstanding
securities of the class owned by such person but shall not be deemed to be outstanding for the purpose of computing the percentage of
the class by any other person.” Rule 13d-3(d)(1)(i)(D)

Therefore, Mr. Bates’ beneficial ownership
includes 15,700,000 shares owned directly by affiliates that he controls, plus 2,608,696 shares of common stock issuable upon conversion
of Series A Preferred Stock he owns, plus 5,286,887 shares of common stock issuable under Series A Preferred Stock owned by Innovative
Digital Investors Emerging Technology, LP (“IDI”), which he controls, for a total of 7,895,583 contingent shares,
and an overall total of 23,595,583 shares. Under Rule 13d-3, his beneficial ownership is thus calculated as 23,595,583 / 57,561,234 (derived
from 49,665,651 + 7,895,583) = 41%.

Similarly, IDI’s ownership includes 11,500,000
shares which it owns directly, plus 5,286,887 shares of common stock issuable under Series A Preferred Stock which it owns, for an overall
total of 16,786,887 shares. Under Rule 13d-3, its beneficial ownership is thus calculated as 16,786,887 / 54,952,538 (derived from 49,665,651
+ 5,286,887) = 30.5%.

The only other persons named in the table whose
ownership includes unissued contingent shares are Erik Nelson and Rykor Energy Solutions, LLC, and their beneficial ownership percenta